DOT drug testing: Reducing problems at collection sites

Undercover Investigations by the Government Accountability Office (GAO) at collections sites for US Department of Transportation (DOT)-certified drug and alcohol test collection sites have found problems. There is a lack of compliance with applicable protocols by collectors and little oversight of collectors and service agents by the Federal Motor Carrier Safety Administration (FMCSA). The agency is responsible for ensuring that motor carriers comply with federal drug testing regulations.

These regulations require commercial motor carriers to have a drug testing program that covers transportation safety-sensitive employees who operate commercial motor vehicles with a gross vehicle rating of 26,001 pounds or more.

Particular problems were noted with the security of the collection process. GAO investigators found conditions that afforded truckers opportunities to adulterate or substitute urine specimens.

Testing

The DOT drug testing process for urine collection requires that only a collector who meets DOT requirements can perform the collection. At the collection center, the collector must verify the driver's identification and then have the driver empty his pockets before proceeding with the collection.

The driver must provide at least 45 milliliters of urine. The collector makes an initial inspection of the specimen, which includes checking the temperature of the specimen, then divides the specimen into a primary and split specimen, seals the bottles and signs paperwork.

The specimens are then sent to a laboratory where the primary specimen is analyzed for marijuana, cocaine, amphetamines, opiates (focused on heroin), and hencyclidine (PCP).

Challenges

The most common problems uncovered at facilities that perform urine collections for DOT-regulated drug tests were:

• Not keeping other people from entering the area where the collection was taking place.

• Not checking photo identification to make sure the right person was taking the test.

• Not asking the person taking the drug test to empty their pockets or take off their outer clothing (to avoid having adulterants carried into the test).

• Bathrooms that have substances, such as soap and cleaning products, that could be used to adulterate or dilute the urine specimen.

One of the challenges with collection sites, said the GAO's report, is that collection sites can be located anywhere. For example, it can be any toilet in a clinic, hospital, or office building; a toilet on site at a carrier's place of business; or a portable toilet.

To help employers be aware of the proper drug collection process, the US DOT's Office of Drug and Alcohol Policy and Compliance (ODAPC) has produced the DOT's 10 Steps to Collection Site Security and Integrity. It identifies important steps that a collector must follow every time a DOT collection is performed.

If these collection process protocols are followed, a person's ability to tamper with their specimen will be significantly reduced, said ODAPC.

The 10 steps are:

1. Pay careful attention to employees throughout the collection process.
2. Ensure that there is no unauthorized access into the collection areas and that undetected access (eg, through a door not in view) is not possible.
3. Make sure that employees show a proper picture ID.
4. Make sure employees empty pockets; remove outer garments (eg, coveralls, jacket, coat, hat); leave briefcases, purses, and bags behind; and wash their hands.
5. Maintain personal control of the specimen and custody and control form (CCF).
6. Secure any water sources, or otherwise make them unavailable to employees (eg, turn off water inlet, tape handles to prevent opening faucets, secure tank lids).
7. Ensure that the water in the toilet and tank (if applicable) has a bluing (coloring) agent in it. Tape or otherwise secure shut any movable toilet tank top.
8. Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are present.
9. Inspect the site to ensure that no foreign or unauthorized substances are present.
10. Secure areas and items (eg, ledges, trash receptacles, paper towel holders, under-sink areas, ceiling tiles) that appear suitable for concealing contaminants.

The ODAPC has also produced a publication containing guidance and best practices for managing a quality drug and alcohol testing program that meets US DOT requirements. The publication is entitled: What Employers Need To Know About DOT Drug and Alcohol Testing.

The document, available for downloading, can be found on the ODAPC's website: www.dot.gov/ost/dapc/index.html.